Access Capital Partners
About

Compliance

 

Compliance

 

Under the responsibility of its senior management team, Access Capital Partners is committed to acting in the best interest of its investors.

 

 

 

 

Regulatory Framework

 

The firm follows strict regulatory frameworks and applies high standards of governance, ethics, and risk management across its business activities.
 

Access is:
 

  • Registered and authorized as an investment manager by the AMF (Autorité des Marchés Financiers - France)
  • Registered and authorized as an AIFM 
  • Registered as a sub-threshold AIFM with the FSMA (Belgium)
  • Authorized as an Exempt CAD Firm by the FCA (United Kingdom)
  • Supervised by the CSSF (Luxembourg)
  • Licensed as an Investment Firm by the GFSC (Guernsey Financial Services Commission)
  • Exempt Reporting Advisor with the SEC (United States)
  • is authorized under the AIFMD to distribute its funds in Spain, Germany, Luxembourg, and other European countries (the firm holds the relevant management passports)

Beyond regulatory authorizations, Access Capital Partners actively adheres to the highest professional standards and best-practice frameworks that govern the private equity and asset management industry.

The firm aligns with the following industry codes, associations, and principles:
 

  • AFG / France Invest - Code of Conduct for private equity management companies
  • Invest Europe - Code of Conduct and valuation standards (International Private Equity and Venture Capital Valuation Guidelines)
  • France Invest - Charter of commitments for responsible investors
  • FATF (Financial Action Task Force) - Anti-money laundering and counter-terrorism financing standards
  • ILPA Principles (Institutional Limited Partners Association) - Alignment of interest, governance, and transparency guidelines
  • Public Pension Fund Reform Code of Conduct
  • Internal Code of Ethics - Access applies its own internal ethics rules, aligned with industry best practices

 

 

1

Conflict of Interest Management Policy

 

Access Capital Partners acknowledges that the nature of the Private Asset business might not be exempt from situations with conflicts of interest. Access Capital Partners will take all reasonable measures to identify and adequately manage every conflict of interest that arise in the course of managing the Funds and Portfolios.

This conflict-of-interest policy applies to each entity of the Access Capital Partners, each staff, each client, third party and investor, all activities and investment services provided.

A conflict-of-interest situation arises from any situation where two or more parties have divergent interests when involved in any given situation. It takes into account any situation when Access Capital Partners or any relevant person is likely to make a financial gain or avoid a financial loss, has a professional or personal interest in the outcome of a service provided to the Fund/ Portfolio and its investors’ which is distinct from the Fund/ Portfolio’s interest in that outcome. A situation of potential conflict of interest may arise even when there is no apparent or obvious improper or unlawful act or disadvantage to a client or an investor.


PREVENTION

The reputation and development of Access Capital Partners is founded on its operational excellence in generating performance and its rigorous commitment to respect ethical principles in all dealings. Activities and investment services are carried out with competence, care, diligence, loyalty, integrity and fairness with the best interests of each client and investor in mind at all times.

Access Capital Partners and its managing partners promote a culture of self-awareness in ethics and conflicts of interest. It has established internal codes and procedures and implemented adequate processes to prevent any conflict of interest from arising.

Those include, without being limited to:

  • Code of Ethics
  • Employment contracts
  • Employee trainings
  • Information barriers
  • Segregation of duties
  • Whistleblowing policy

MITIGATION MEASURES

All potential risks of conflict of interest within the scope of Access Capital Partners activities and services are mapped along with adequate mitigation measures and reflected in the following processes and procedures:

  • Allocation policy
  • Personal transactions
  • Outside business Interests
  • Gifts and entertainment Policy
  • Remuneration Policy
  • Outside service providers relation
  • Market abuse policy
  • Voting right policy/ Shareholder’s engagement policy
  • Investment policy
  • Legal and social life of funds​​​



DETECTION AND RECORDING

Access Capital Partners Group monitors and records each arisen conflict of interests in a dedicated register, which shall include all remediation or corrective actions taken.

Access Capital Partners will review and analyse arisen conflicts of interests within the register in accordance with laws and regulations.


RESOLUTION

Any arisen situation of conflict-of-interest conflict which may arise with a direct or indirect impact shall be reported to Senior Management.

Advice from the fund/AIF Advisory Board shall be sought for when remediation actions are not deemed sufficient to protect the interests of each investor.

 

2

Complaints Handling Procedure

 

Access Capital Partners has established and maintains an operational procedure for the prompt, objective, and efficient processing of customer complaints. It responds to the prin-ciples of transparency with respect to the customer, providing objective information at no charge.

Any complaint can be sent either by postal mail or electronic mail to:

Access Capital Partners
42 rue Washington
75008 Paris, France

+33 (0)1 56 43 61 00
complaints@accesscp.com

An acknowledgment will be issued within 10 business days from the day of receipt, and a response will be provided within two months, unless exceptional circumstances apply.

 
In case of persistent disagreement, clients may contact the AMF Ombudsman:

Médiateur de l’AMF - Autorité des Marchés Financiers
17, place de la Bourse - 75082 Paris Cedex 02, France
The AMF Mediation Charter is available on their official website.

 

3

Information on Financial risks and Disclaimer

 

Access Capital Partners reminds users that its funds are long-term funds and not capital guaranteed, which entails risks of capital loss. The funds are exposed to risks affiliated with non-listed companies on the regulated market, among other risks.

  • Market risk: The potential for adverse changes in the fair value of the Funds’ investment portfolio. Categories include currency risk, interest rate risk, and other price risk.
     
  • Interest rate risk: Exposure to changes in yield curves, interest rate volatility, and credit spreads.
     
  • Currency risk: Exposure to changes in spot prices, forward prices, and currency.
     
  • Exchange rate volatility.
     
  • Other price risk: Fluctuation in the value of instruments due to market price changes other than currency or interest rate risk.


Access Capital Partners also reminds users that past performance is no guarantee of future performance, that the value of investments may fluctuate up or down, and that the value of shares depends on the value of the securities in the portfolio.

Consequently, investors may not recover their initial investment and have no guarantee of income.

The purpose of this website is to present the activities of Access Capital Partners and provide information about its products to the public. The material posted on the site is intended for information purposes only and is valid at the time of posting. It is nonetheless incomplete owing to the necessarily simplified nature of the content, and is not contractually binding. The information does not represent an offer of products, a recommendation, or a solicitation to purchase securities or raise capital.

Online users are reminded that any investment in Access Capital Partners entails a degree of risk. Consequently, and prior to any investment decision, users are advised to familiarise themselves with the regulatory documents. Potential investors should contact their usual advisor with any questions about the tax treatment of these products.